Hundt is one of the principals behind Frontline Wireless, a prospective nationwide wireless-services provider who like Google and other players is seeking a beneficial tweak to the auction rules. But as the politically savvy Hundt notes, “at any given moment, Verizon could have 70 lobbyists at the FCC,” he said. “So the odds are really still against any upstart like us.”

Calling Frontline and Google ‘upstarts’ may not be paying enough respect to the heavy hitting on both teams’ benches. Frontline, whose plan calls for a network that prioritizes public-safety communications and embraces a provider- and equipment-neutral infrastructure, counts Silicon Valley kingmaker John Doerr among its early backers.

According to documents filed with the FCC, Doerr met with FCC chairman Kevin Martin during Martin’s recent visit to Silicon Valley, to champion Frontline’s cause. Martin, who also toured Google during his visit, gave praise to Frontline’s proposal at the last open FCC meeting, touting it as a possible option for inclusion in the final rulemaking.

While Hundt admires Google’s spectrum-auction idea (it is similar, but different to part of Frontline’s plans, he said) and has immense respect for the company’s ability to execute, Hundt knows full well the probability of success in battling established D.C. powers like the big telcos.

“I’m never surprised by anything about Google,” Hundt said. “If they decided to go into the rocketship business, they’d be a success.” But beating Verizon, AT&T and other expected opponents, like the entire cellular industry, may be harder to overcome than gravity’s simple pull.

“We expect Verizon’s comments to make [Frontline’s proposal] sound like the moral equivalent of global warming,” said Hundt. Neither Verizon nor AT&T had yet filed comments with the FCC on the proposed rulemaking as of Tuesday afternoon.

Wednesday’s comments deadline will be followed by another deadline a week later, when comments are due on the comments. Then there will be more discussion and lobbying as the FCC attempts to finish drafting the rules by a late-June timeframe, which according to Hundt still has some wiggle room. The FCC would like to give prospective bidders as much time as possible to prepare for the actual auction, which by law must take place before the end of January 2008.